GENERAL40341

• Permit No: C1980001
• IBM Index Class Name: General Documents
• Doc Date: 2/22/1990
• Doc Name: Midterm Review Findings Document
• Permit Index Doc Type: Findings
• Media Type: D
• Archive: No

14. Narrative on pages 4.4-39 and 2.4-11 should be revised to include the
entire Moffat area herbaceous species diversity commitment as it is
stated in the Division's 1987 Findings Document: "Reclaimed areas will
have at least five (5) perennial species with relative importance equal
to or greater than 4%, but with all five (5) species combined not to
exceed 75% in relative importance and with any one of these five (5)
species not to exceed 40% in relative importance." furthermore, the
Division requests that P&M expand on the statement in the letter dated
December 5, 1983 from Mike Campbell to Carol Russell (part of
Appendix 2.4-B.) that ", ... the Mine will establish vegetation similar
to the relative important species with regard to life form and
seasonality." What life forms will the five species, which will be
established as part of the diversity standard, represent?
15. Table 2.4-45 should be revised to eliminate several mistakes that it
presently contains. The value for -Pi log Pi for BRIN should be
0.1591 instead of 1.7262. Thus, the sum of values in the -Pi log Pi
column should be 0.6078 rather than 2.1799. These changes require that
all values in the column labeled "Percent Contribution to Diversity" be
recalculated.
16. Pages 1 and 2 of Appendix 2.4-8 should be revised to reflect that the
table t value used in the sample adequacy equation will equal 1.64
regardless of the type of vegetation community. P&M may refer to page 15
of the Division's Revegetation Guidelines for clarification of this
subject.
17. Pages 4.4-1 and 4.5-1 identify rangeland as the primary postmining land
use for the Edna Mine permit area. Rule 1,04(71)(c) defines rangeland as
"land on which plant cover is principally valuable for forage. Except
for brush control, management is primarily achieved by regulating the
intensity of grazing and season of use." With this in mind, the Division
requires P&M to adjust Section 4.5 - "Land Management Plan" to correctly
address compliance with Rules 4.15.7(3)(d), 4.15.7(3)(e), 4.15.7(3)(f),
4.15.1(3), 4.15.5(1) and 4.15.5(2). More specifically please address at
least the following issues:
A. What management technique is being or will be observed with regard
to reference areas? (Rules 4.15,7(3)(d), 4.15.7(3)(e), and
4.15.7(3)(f)).
B. The rules and the permit itself (page 4.5-1) call for implementation
of a grazing plan in the last two years of the extended liability
period. How does P&M intend to keep livestock off newly reclaimed
areas i n compliance with Rule 4.15 .5 (1 )?
C. What measures will P&M employ to preclude interference by grazing of
vegetation monitoring and sampling in compliance with Rule 4.15.5(2)?
D. In compliance with Rules 4.15,1(3) and 1.04(71)(c), please indicate
the seasons (specific dates) during which all varieties of livestock
will be grazed each season, the numbers of livestock to be grazed
each season, and the methods by which the permittee will demonstrate
to the Division, prior to initiation of grazing, that..-the area to be
grazed is adequately established.
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